United States Environmental Protection Agency (EPA) signed a Consent Agreement and Final Order with Lehigh Cement Company (Lehigh), which settles an administrative matter involving violations of the National Emission Standards for Hazardous Air Pollutant for the Portland Cement Manufacturing Industry. EPA issued a Notice of Violation/Finding of Violation (NOV/FOV) to Lehigh on May 10, 2007. The NOV/FOV specifically alleges that the Respondent violated the Portland Cement NESHAP when it discharged from one of its clinker coolers particulate matter (PM) an average of 0.13 pounds per ton, which exceeds the applicable NESHAP PM limit of 0.10 lbs/ton. During the April 8, 2007, 113 Conference, Lehigh informed EPA Region 5 that the exceedance was due to inappropriately designed bags in its clinker cooler baghouse. Lehigh further explained that upon discovery of the exceedance that it immediately took corrective action to replace the bags. To determine if the replacement of the bags brought the clinker cooler into compliance, Lehigh conducted a second stack test on October 30, 2007. The stack test results demonstrated that the facility was still out of compliance with the Portland Cement NESHAP PM limit. Upon immediate investigation, Lehigh discovered that the bag snap bands recommended by the General Electric were the wrong size. Lehigh replaced the bands on December 7, 2007, and, on February 12, 2008, conducted a third stack test. The third stack test was in compliance wit